Abstract The study examines global approaches to information security by comparing data protection practices in the media sphere across the United States, France, Switzerland, Denmark, China, and Kazakhstan. It analyzes the laws and regulations of these countries, comparing key norms and designs in relevant documents, and assesses the security levels of national information systems against hacker attacks and unauthorized access through statistical data. The research utilizes historical legal and comparative legal methods to interpret and analyze the legal norms of each country. The findings reveal that information security is a top priority for national security. The United States has implemented a complex, multilevel, and interconnected cyber defense system, built on a structured logical matrix. EU countries have national systems focused on specific sectors (e.g., banking in Switzerland, corporate data protection in Denmark). China’s system is characterized by complexity and diverse strategies but is tightly regulated with strong accountability and control. Kazakhstan, on the other hand, is more effective within international organizations and regional projects, particularly in cooperation with Central Asian countries.
Nyssankuatova et al. (Wed,) studied this question.